Failure to Kneel

For many passengers, the 14-inch drop from the bottom step of a high-floor transit bus or a motorcoach is challenging. Keep in mind that:

In transit service, drivers do not assist or even spot boarding or alighting passengers.

While motorcoach drivers typically assist or spot boarding or alighting passengers at the front door, the drivers of motorcoaches deployed in commuter/express service (provided by transit agencies or companies under contract to them) do not.

Other than with one door configuration one occasionally finds on a transit bus, and never on a motorcoach, there are no handles extending outward from the door — a configuration that makes alighting even more dangerous than it already is, compared to boarding.

To address these risks, full size transit buses and motorcoaches (almost all of which contain pneumatic suspension systems) contain a clever feature that allows drivers to release air from the right front air bag and lower the front stepwell (or the front right corner of the floor on a low-floor transit bus) between 4 and 5 inches. This capability of these vehicles is referred to as a “kneeling feature.”

Kneeling the right-front corner of these buses is an industry standard when the vehicle’s front door is not pulled adjacent to a curb. And it is customary to kneel this door position, even with a curb present, for passengers visibly disabled (including cane users).[1] However, while a typical policy requirement and an industry standard, kneeling the right front corner of a bus or motorcoach is not a regulatory requirement.

Regardless, when a transit bus or motorcoach is pulled to the curb, the step down from the bottom step (14 inches on a traditional high-floor bus, and 12 inches on a low-floor, ramp-equipped bus) is lowered to roughly 9 or 7 inches, respectively, from the ground level. Where this is done at a curb (e.g., for elderly and disabled individuals), the passenger’s step up or down may only be 5 to even 3 inches.

Another caveat of the general industry-standard for kneeling a bus or coach’s front door position is that this is reasonable and prudent when (a) the door is more than three or four feet from the curb, (b) when there is no curb, or (c) when the passenger boarding or alighting is clearly elderly, disabled, a child, or someone else who is likely to have difficulty ascending or (more importantly) descending from a 14-inch-high bottom step (for a high-floor bus or a motorcoach) or a 12-inch-high floor surface (of a ramp-equipped, low-floor bus). In the latter case, the ramp should be extended for wheelchair users (in every case), walker users or passengers with another mobility-assistance device (e.g., cane), as well as someone elderly or with another disability [A]. As a practical matter and the industry standard, any passenger can request that the driver kneel the bus at this door position. Such requests are generally honored.

Because kneeling the vehicle down and up takes all of about six seconds, this maneuver should be done if there is any reasonable possibility that a passenger might need it. This is particularly true for alighting passengers, since (a) any difficulties they may have in ambulating should be obvious to the driver when they board, plus (b) alighting is more risky than boarding — although passengers falling forward while boarding a stepwell can indeed be injured, particularly if one’s shin strikes the edge of a step. Many drivers simply kneel the bus at every stop. Plus, motorcoach drivers in tour, charter or intercity/scheduled service “duty cycles,” and who themselves should first alight to assist or “spot” passengers boarding or alighting, should first kneel the vehicle.

It is a curiosity that few transit buses are “configured” to kneel at the rear door, since the technology for this is just as easy and low-cost as doing this for the front door. Further, many drivers do not pull their rear doors parallel to, and as close to, the curb or roadway edge as they should (see discussion in next subsection: “Pulling Adjacent to the Curb”), forcing alighting passengers to step down into a triangular or trapezoidal space. Yet finding a rear-door kneeling feature is a rarity. And when combined with a pull-in that places the rear door in one of these positions, the risk of a passenger injury is reasonably foreseeable.[2]

Policy requirements technically governing this procedure in transit service are very difficult to monitor — much less in a mode whose where drivers are actually encouraged to commit safety compromises (with a wink) because the principal goal is often to get drivers to comply with unreasonably tight schedules. Motorcoach drivers, whose schedules are not nearly as tight as most transit systems’ schedules are, generally do kneel their vehicles at the front (and only door for vehicles for this type). This is true largely because, in most motorcoach sectors (computer/express service excepted), drivers stand at the bottom of the stepwell to “spot” and/or assist passengers onto and off of the stepwell, as an industry standard. So drivers kneel the front stepwell partly to get on and off the vehicle themselves, and partly to help the passengers on and off. Regardless, no driver of any service will likely testify that efficiency or on-time performance (or reliability) is more important than safety. This is “the big lie” in public transportation.

Testifying that safety “comes first” is the Big Lie in almost every mode of public transportation service.

As a safety compromise, failing to kneel the bus or coach at the front door would seem like an asterisk, since it takes roughly six seconds to lower and then raise the stepwell, combined. Yet if a driver does not do this a few dozen times on a run (which a transit driver has an opportunity to do, with the stops so frequent), the driver can create several minutes of recovery time. Lest the reader think there is little incentive for a driver to stretch recovery time by two minutes, if the route’s schedule has no recovery time, despite the countless other safety compromises relentlessly committed by transit drivers, two minutes per run can make a difference. Plus, drivers who are supposed to be highly alert, and constantly driving “defensively” every nanosecond their vehicles are in motion, operate under a considerable degree of stress. So having a few minutes at the end of each run to merely ward off fatigue is an important component of a safe route and schedule. But when schedules are too tight, these few minutes can only be created by the commission of safety compromises.

Regardless, a surprising number of boarding and alighting accidents come from the failure to kneel the bus’ right-front corner. The most typical victim of this compromise is an elderly or disabled rider, an obese rider or a child. For such individuals, stepping down 14 inches is challenging. Plus, unless the victim is the first one off the bus (and even when he or she is), that passenger is not likely to know how far from the curb the door is, and thus, how far the drop to the ground surface or curb may be. This is especially true if drivers on most trips indeed kneel the bus for most passengers, and suddenly one driver does not. Broken hips, broken ankles and knee injuries are common consequences.

Finally, the technical specifications which most transit agencies use to define the kneeling features are often configured backwards. They can almost always be configured in one of two ways:

Pulling into a stop, the bus’ curb-side front corner can kneel and the doors can then open. And after the last passenger boards or alights, the doors can close and the curb-side front corner can then be raised.

Pulling into a stop, the bus’ front door can open and the curb-side front corner can be kneeled. Then, after the last passenger boards or alights, the curb-side front corner can be raised, and then the doors can be closed.

The distinction between these two scenarios may seem subtle. But the second of these scenarios can effectively transform the stepwell into an escalator — something bus passengers hardly expect. TA President Ned Einstein has served as an expert witness where a foolishly-configured kneeling feature began rising, with the door still open, and a passenger catching his bus at the last minute leaped onto the stepwell — only to find himself on an escalator, and nearly tearing his arm out of its socket in his effort to not tumble backwards down the moving stepwell. Mr. Einstein served as an expert on a similar case where two elderly passengers were alighting when the stepwell began descending — and with the door still open, tumbled down their “moving stepwell” onto the sidewalk below. Unlike the time-savings derived from other kneeling feature failures, this quirk saves no time. So it is not even a genuine safety compromise. It is simply the result of ignorance or indifference. Individuals who prepare vehicle specifications for a transit agency (typically a senior maintenance official) should know better.

[1] Walker users should be boarded and alighted via an accessible vehicles’ wheelchair lift. However, this is not often done on a high-floor transit bus, and rarely done for a walker user boarding or alighting from a motorcoach. They should obviously board and alight via the ramp on a low-floor vehicle.

[2] Motorcoaches do not have rear doors for regular alighting, although they increasingly have rear doors equipped with wheelchair lifts. Otherwise, transit passengers are not allowed to board at the rear door, since fares can only be collected (or passes observed, etc.) at the front door, where the driver and farebox are positioned.

[A] In some cases, particularly on low-floor vehicles, and particualrly when vehicles are kneeled, some of these ambulatory or semi-ambulatory passengers may step on or off the stepwell or floor before the driver has a chance to perform this task.

Safety Compromises is an initiative of veteran expert witness and consultant Ned Einstein and Transportation Alternatives (http://www.transalt.com), part of a network of websites established to educate and inform members of the legal profession about critical safety issues in public transportation. Visit Transportation Alternatives' website to learn directly about Mr. Einstein's services and expertise in the field.